Privacy Policy

Lingowl ("the App", "we", "us", "our"), operated by Tranquil Mind Technology JSC, respects your privacy. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have. By using the App, you agree to this Policy.

Lingowl is an AI-powered English learning app that lets you practice speaking through real-time conversations, roleplay scenarios, and automatic pronunciation and grammar feedback. You sign in with your Google account so we can save your learning progress across sessions and devices.

1. Information We Collect

We collect only the data described below. Data processed entirely on your device (for example, locally cached lessons and progress) is not covered here unless it is transmitted to us or a service provider.

Information you provide

• Account information — when you sign in with Google, we receive your name, email address, Google account identifier, and profile photo URL.
• Voice recordings — when you use speaking features, we access your microphone. For live conversation practice, speech is recognized on your device and only the resulting text leaves your device. For pronunciation practice, a short audio clip of your speech is recorded and sent to Microsoft Azure to score your pronunciation. Audio is processed to generate feedback and is not retained as stored recordings after processing.
• Conversation and learning content — the text of your conversations, roleplay messages, quiz answers, and similar learning input you generate in the App.

Information collected automatically

• App activity — screens viewed, features used, and in-app interactions.
• Learning progress — lessons completed, vocabulary learned, streaks, study time, and error statistics, synced to your account.
• Crash logs and diagnostics — error reports and performance data to keep the App stable.
• Device and other identifiers — app-instance and analytics identifiers, the advertising identifier (Advertising ID), plus basic device and operating-system information.

The App is free and supported by advertising. Ads are served by Google AdMob and its mediation partners, which may use your advertising identifier and device information to show and measure ads (see Section 3). We do not collect your precise or approximate location, contacts, or photos.

2. How We Use Information

• Provide and operate the App, including AI conversations, pronunciation and grammar feedback, and roleplay.
• Save and sync your learning progress and personalize practice to your mistakes.
• Analyze usage and diagnose crashes to improve the App.
• Display advertising and measure ad performance and revenue through our advertising and attribution partners.
• Maintain security and prevent fraud or abuse.
• Comply with legal obligations.

We do not sell your personal information, and we do not use the content of your conversations or voice recordings to serve ads.

3. Third-Party Services

We share data with the following service providers strictly to operate the App. Each processes data on our behalf under its own privacy terms.

These providers process data on our behalf or for the advertising and measurement purposes described above. Our AI and speech providers act as our processors/service providers, are not permitted to use your data for their own purposes, and API-based AI processing is not used to train their models by default.

4. How We Share Information

We do not sell your personal information for money. We share data only: (a) with the service providers listed in Section 3 to operate the App; (b) with advertising and attribution partners (Google AdMob, its mediation partners, and Adjust) that receive your advertising identifier and device information to show and measure ads; (c) when required by law or to protect rights and safety; and (d) in connection with a merger, acquisition, or business transfer, subject to this Policy. Depending on your region, sharing data with advertising partners may be considered a "sale" or "sharing" under laws such as the CCPA/CPRA; you may exercise the choices described in Section 7.

5. Legal Bases (EEA/UK — GDPR)

We rely on: contract (to provide the App and account features you request); legitimate interests (core functionality, security, and improvement); consent (where required, e.g. microphone access and, in the EEA/UK, personalized advertising collected via a consent prompt); and legal obligation (compliance and recordkeeping).

6. Data Retention

We keep account and learning data for as long as your account is active. Crash and diagnostic data is kept for a limited period. Voice audio is processed transiently and not retained as stored recordings. When you delete your account (Section 7), we delete your associated data as described, except where retention is required by law or for fraud prevention (up to 90 days).

7. Your Rights and Account Deletion

Depending on your region, you have rights to access, correct, delete, port, object to, or restrict processing of your data, and to withdraw consent — including GDPR (EEA/UK), CCPA/CPRA (California), LGPD (Brazil), and PIPEDA (Canada) rights. You may also complain to your local data protection authority.

Delete your account and data — two ways:

• In the app: open Settings → Delete Account and confirm. Your account and associated data are permanently deleted.
• By email: contact contact@tranquilmind.co from your account email and we will delete your account within 30 days.

To exercise any other right, contact us at contact@tranquilmind.co.

8. Children's Privacy & Child Safety Standards

The App is intended for users aged 13 and older and is not directed to children under 13. We do not knowingly collect personal information from children under 13; if we learn we have, we will delete it. Where a higher age of digital consent applies (e.g. parts of the EEA), that age governs.

Child Safety Standards (CSAE) — Lingowl (developed by Tranquil Mind Technology JSC) has zero tolerance for child sexual abuse and exploitation (CSAE) and child sexual abuse material (CSAM):

• We prohibit any content or conduct that sexualizes, exploits, or endangers minors — across images, video, audio, and text, including AI-generated content. This covers grooming, sextortion, solicitation, trafficking, and any attempt to create, request, share, or promote such material. These rules apply to both what users type into the App and what the AI generates in response.
• Prevention: AI conversations are generated through our AI provider (OpenAI) whose systems include built-in CSAE safety filters, and our system prompts constrain the AI to English-language learning. The App has no user-to-user messaging, content sharing, or public communication — users interact only with the AI tutor — which removes user-to-user CSAM exchange.
• Reporting and response: you can report any concern or suspected violation to our child-safety contact at contact@tranquilmind.co. We review reports, remove violating content, and may suspend or terminate access. We report apparent CSAM to the National Center for Missing & Exploited Children (NCMEC) and/or local authorities as required by law.
• We comply with applicable child-safety laws and align with the Google Play Child Safety Standards policy.

Child-safety point of contact: contact@tranquilmind.co.

9. International Data Transfers

Your data may be processed in countries other than your own, including the United States. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) for these transfers.

10. Data Security

We use encryption in transit (HTTPS/TLS) for all data leaving your device and apply reasonable technical and organizational measures. No method of transmission or storage is 100% secure.

11. Changes to This Policy

We may update this Policy. Material changes will be posted here with a new "Last updated" date. Your continued use of the App after changes take effect constitutes acceptance.

12. Contact Us

Tranquil Mind Technology JSC
No. 3, Alley 98, Vu Trong Phung Street, Thanh Xuan Ward, Hanoi City, Vietnam
Email: contact@tranquilmind.co